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Ex Parte Meeting for Proposed Rule 79 FR 59898

  • Title:
    Conference Call with Mr. William Harrington and Mr. Rick Michalek

    Ex Parte No: 1016
    Date: 5/12/2015

    Meeting Date:

    Tuesday, May 12, 2015

    CFTC Staff:

    Paul Schlichting, Stephen Kane, David Aron, Francis Kuo, Rafael Martinez

    Organization(s):

    none, individual citizens

    External Attendees:

    William Harrington (individual), Richard Michalek (RJM Consulting)


    Federal Reserve Board of Governors (FRB)
    Office of Comptroller of the Currency (OCC)
    Federal Deposit Insurance Corporation (FDIC)
    Federal Housing Finance Agency (FHFA)
    Farm Credit Administration (FCA)

    Additional Information:

    Commenters argue against an exemption from margin requirements for issuers of asset backed securities. Commenters believe ABS issuers' current practice for dealing with counterparty credit risk is inadequate by construction and presents a systemic risk. See attached presentation.


     


    Conference call was joint with staff of Prudential Regulators.